Briefing: Updates on the UBO Billing Policy Manual Date: 20 March 2007 Time: 1400 - 1450

1. Briefing: Updates on the UBO Billing Policy Manual Date: 20 March 2007 Time: 1400 - 1450

2. Objectives • Understand the reasons for the revision • Recognize key issue changes • Identify areas that need further revision • The material presented outlines the current content of the manual • Further revisions are needed

3. Overview • Service-specific provisions are stricken from the manual • UBO wanted to hyperlink references and documents for easy access and review • This did not meet DoD publication standards • Chapter 6 in the 1997 manual – split into two chapters • Chapter 6 – Charges for Medical Services • Chapter 7 – Subsistence

4. Chapter 1 - Introduction Purpose • Terminology change: • “uniform management system for Military Treatment Facility (MTF) business office functions” became • “standardized guidance for the business office portions of the revenue cycle function at Military Treatment Facilities (MTFs)” • Expands the MSA billing activity description to specify types of patients for whom MSA billing is appropriate • Expands the description of Third Party Collection

5. Chapter 1 - Introduction Responsibilities • Terminology changes – doesn’t change the substance • New description of Defense Manpower Data Center (DMDC) • Reflects its responsibility for SIT, OHI, and DEERS

6. Chapter 1 - Introduction Responsibilities (continued) • New responsibility for TMA • Maintain a database of all Service policies and procedures issued to implement this guidance document • Ensures Service policies and procedures are in compliance with this guidance document, and clarifies the purpose of the marketing program is “to achieve maximum Other Health Insurance (OHI) capture” • Military Department Secretary responsibility

7. Chapter 2 - Compliance In General • Complete revision of the April 1997 manual • Brings compliance to the forefront of billing activities • Basically modeled after Compliance Guidance documents issued by the Department of Heath and Human Services Office of Inspector General • Adjusted to meet the unique needs of the Military Health System

8. Chapter 2 - Compliance • Portions of the April 1997 manual moved to other parts of the new manual Example: Discussions of the MSA and TPC office locations are inserted in the respective chapters addressing each specific office • Recommendations for auditing and monitoring activities • Audit checklist is under revision

9. Chapter 3 - Medical Services Account In General • No change in overall issues • Service-specific references have been stricken • “Medical services” = “medical and dental services”

10. Chapter 3 - Medical Services Account Appointment of the MSA Officer • The MSA officer mustbe a commissioned officer, NCO, warrant officer, or civilian employee • A contractor may not serve as an MSA officer

11. Chapter 3 - Medical Services Account Responsibilities of the MSA Officer • Provide relevant charge information to patient admissions personnel • Originally, the MSA Officer had to ensure that “patients are aware of” relevant charges • Deposit and internal control procedures are revised

12. Chapter 3 - Medical Services Account Transferring MSA Officer Responsibilities • References to “FSO, DAO, and DO” stricken • Replaced with “servicing accounting and finance offices”

13. Chapter 3 - Medical Services Account Change Funds • Additional clarity on obtaining the change fund authorization Minimum Internal Controls • Additional guidance for manual reporting when automated reporting is not available or otherwise appropriate

14. Chapter 3 - Medical Services Account Loss of Funds - What to Do • Notify the MTF commander if a loss or deficiency of Government funds, vouchers, or papers is discovered • The MTF commander submits a request for an investigation from the base or post • If a loss occurs, take action as outlined in the FMR

15. Chapter 3 - Medical Services Account Charging Non-DoD Beneficiaries for Medical Care • Civilians who are not covered beneficiaries must be charged • They are treated at their own expense and billed using an I&R • These patients must complete DD Form 2569

16. Chapter 3 - Medical Services Account Charging Non-DoD Beneficiaries for Medical Care • Unlike the Third-Party Collections Program, the amount collected from non-DoD beneficiariesmust be used for specific activities: • Trauma consortium activities; • Administrative, operating, and equipment costs • Readiness training • MTFs may bill the payer – this is not mandatory • Non-DoD beneficiaries must acknowledge their responsibility for payment not received from the payer

17. Chapter 3 - Medical Services Account Billing Non-Uniformed Services Beneficiary Patients During Contingency Operations • Manual outlines when to bill and when not to bill • BOTTOM LINE: The UBO is not responsible for healthcare billing operations in deployed, non-fixed medical facilities • The UBO sets the rate and billing mechanism • It is up to the Services to implement

18. Chapter 3 - Medical Services Account Billing State Agency Sponsored Programs • Follow Service-specific guidelines for filing claims to state agency sponsored programs and for uncollected debt • Bill Medicaid on behalf of Non-Uniformed Services Medicare-eligible emergency patients at full rate

19. Chapter 3 - Medical Services Account Billing State Agency Sponsored Programs - Medicaid • The MSA Officer may also bill the patient directly for physician’s services if Medicaid does not pay • Partial payments are accepted as payment in full • Give the patient an itemized bill for the services rendered

20. Chapter 3 - Medical Services Account Health Care Billing for IMET, Foreign Military Sales (FMS), NATO • Get a copy of the invitational orders for Healthcare Billing for International Military • Use the annual Medical and Dental Rates package for: • Charges for health care • Responsibility for payment • Collection and processing of bills

21. Chapter 3 - Medical Services Account Elective Cosmetic Surgery • Charge all patients for elective cosmetic surgery rates • The rates are in the medical and dental rates • Implants and procedures must comply with FDA guidelines • Patients must sign a letter acknowledging the debt • File a copy of the letter in the MSA office accounts receivable file

22. Chapter 3 - Medical Services Account Workers Compensation • DoD beneficiary – follow MAC guidance – Chapter 6 • DoD employees – Do Not bill – this is explained in the manual • Non-DoD beneficiaries – MSA rules

23. Chapter 3 - Medical Services Account Disposition of Records • The period of record retention is increased to Six (6) years, Three (3) months

24. Chapter 4 - Third Party Collection Program Overall • Chapter more clearly outlines what it takes to have an effective TPCP • Examples: • Adds requirement for a review of all aspects of the revenue cycle • Was accounts receivable management • Lists the minimum participants in that cycle • A/R mgt, QA/UR, Admissions, etc.

25. Chapter 4 - Third Party Collection Program Medical Services Billed • Lists the billable services • Inpatient hospital care • Observation • APVs • Anesthesia • Outpatient • Ancillaries (lab, path, rad, prescription drugs) • Immunizations/injections • Dental • Ambulance • DME

26. Chapter 4 - Third Party Collection Program Medical Services Not Billed • Adds a requirement to notify TMA about any services for which rates are not established Identifying Beneficiaries Who Have Other Health Insurance (OHI) • Use the new DD Form 2569 • Allows for copying the front and back of the insurance card • Information may be stored electronically

27. Chapter 4 - Third Party Collection Program Authorization to Release Medical Information in Support of TPC • Revised to reflect implementation of the HIPAA Privacy Rule • Release only the minimum necessary information to private insurers

28. Chapter 4 - Third Party Collection Program Collection Activities • Removes 30-day follow-up requirement • Adds a90-day follow-up requirement • Adds guidance on collection of interest payments • Payment plus interest cannot exceed billed amount, etc. • Specifies TPC claims files shall be maintained for at least 6 years, 3 months

29. Chapter 5 - Medical Affirmative Claims In General • “Contractually-based insurance” replaces “tort-based insurance” • Deposits are made to the MTF O&M account • Authorized by federal law Recovery Judge Advocate • Expands Recovery Judge Advocate responsibilities Example: Contact TRICARE Claims processor to ensure all Government expenses are included in claim assertion

30. Chapter 5 - Medical Affirmative Claims MTF Responsibilities • Expands procedures and documents to be used to identify and support potential MAC claims Example: Use existing TPC Program procedures and documents to the greatest extent possible to identify potential MAC claims and provide applicable accident and injury information

31. Chapter 6 - Charges for Medical Services In General • Offers more statutory authority • Inpatient charges are DRG-based rates • Incorporates outpatient itemized billing • TRICARE Resource Sharing Agreement • Bill third party as with any comparable service

32. Chapter 6 - Charges for Medical Services Inpatient Rates • Newborn charge updates Outpatient Itemized Billing • Replaces the previous outpatient billing with changes due to outpatient itemized billing

33. Chapter 6 - Charges for Medical Services Overseas Outpatient Charges • Can bill non-beneficiary’s third-party insurer • Charge patients for: • Office visits • APVs • Follow-up visits for evaluation and management • Referral visits to other clinics within the MTF • Prescription refills and/or renewals, when consultation or evaluation by a healthcare provider is not required • No longer AT NO CHARGE

34. Chapter 6 - Charges for Medical Services NO CHARGE for: • Weight checks • Blood pressure follow-ups • Follow-ups to check bandages, dressings, sutures, casts • Cast removal (if cast was applied at MTF) • Vision tests for military driver’s license • Dependent school children visits (including sports physicals) • Follow-up contact lens adjustment • Physical exams for pre-adoptive dependents • Pre-employment physicals if required for federal positions • Patient education

35. Chapter 7 – Subsistence Charges In General • Implements NDAA FY05 changes • AD and retirees do not pay subsistence charges Subsistence Charges • Purpose and what is included in subsistence charges

36. Chapter 7 – Subsistence Charges Collection and Disposition of Subsistence Charges • Funds collected/deposited locally • MSA office attempt collection at time of discharge • Date of billing = date of discharge • If charges not paid in 30 days, MSA office will follow up with delinquent letter

37. Chapter 7 – Subsistence Charges Collection and Disposition of Subsistence Charges (continued) • No charges to transient patients • For military academies, MSA office will submit DD Form 139 to appropriate service • MSA office collects monies from trustees/sponsors for mentally incompetent patients

38. Chapter 7 – Subsistence Charges Discount Rate • Changes “Exemption from charges” to “Discount rate” • Per the FMR, the MSA officer must charge a discount rate to the following: • Spouses/Dependents of enlisted personnel in grades E-1 through E-4 who are not patients • Members of non-profit youth groups are permitted to eat in dining halls (e.g., Civil Air Patrol, Junior Reserve Officer Training Corps and Scouting units)

39. Chapter 7 – Subsistence Charges Discount Rate (continued) • Officers, enlisted members and civilian employees who are not receiving the meal portion of per diem and are: • Performing duty on government vessel • On field duty • In a group travel status • Included in essential unit measuring (EUM) as defined in Joint Federal Travel Regulation

40. Chapter 7 – Subsistence Charges Discount Rate (continued) • Officers, enlisted members, and federal employees who are not receiving the meal portion of per diem and are on a US government aircraft on official duty as a passenger or crew member engaged in flight operations • Or they are involved on Joint Task Force operations other than training at temporary US installations or using temporary dining facilities

41. Chapter 7 – Subsistence Charges Standard Rate • Per FMR, MSA officer must charge the standard rate for meals served to all officers, enlisted members, and federal civilian employees receiving an allowance for subsistence, and who are authorized to eat in DoD appropriated fund dining facilities • This includes Reserve Component officers on inactive duty training

42. Summary • Understand the reasons for the revision • Recognize key issue changes • Identify areas that need further revision • The material presented outlines the current content of the manual • Further revisions are needed